Patrick Knowles v. Iowa (525 U.S. 113)
U.S. Supreme Court · decided December 8, 1998 · Supreme Court Database (Spaeth)
- Citation
- 525 U.S. 113 · 119 S. Ct. 484
- Decided
- December 8, 1998
- Term
- October Term 1998
- Vote
- 9–0
- Majority author
- Justice Rehnquist
- Issue area
- Criminal Procedure
- Disposition
- Reversed and remanded
- Outcome
- Petitioning party won
- Ideological direction
- Liberal
- Constitutional ruling
- State/territorial law held unconstitutional
Opinion excerpt
CHIEF Justice Rehnquist delivered the opinion of the Court. An Iowa police officer stopped petitioner Knowles for speeding, but issued him a citation rather than arresting him. The question presented is whether such a procedure authorizes the officer, consistently with the Fourth Amendment, to conduct a foil search of the car. We answer this question "no.” Knowles was stopped in Newton, Iowa, after having been clocked driving 43 miles per hour on a road where the speed limit was 25 miles per hour. The police officer issued a citation to Knowles, although under Iowa law he might have arrested him. The officer then conducted a foil search of the car, and under the driver’s seat he found a bag of marijuana and a “pot pipe.” Knowles was then arrested and charged with violation of state laws dealing with controlled substances. Before trial, Knowles moved to suppress the evidence so obtained. He argued that the search could not be sustained under the "search incident to arrest” exception recognized in United States v. Robinson, 414 U. S. 218 (1973), because he had not been placed under arrest.. At the hearing on the motion to suppress, the police officer conceded that he had neither Knowles’ consent nor probable cause to conduct the search. He relied on Iowa law dealing with such searches. Iowa Code Ann. § 321.485(l)(a) (West 1997) provides that Iowa peace officers having cause to…
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